IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsNov 28, 2001
…e conceded that he is not entitled to the $27 deduction, having never claimed this deduction on his 1997 income
tax return in the first instance and having failed to address the
issue before, during, or after the trial.
Although petitioner’s 1997 income tax return reflects a
claimed deduction of $5,807 for a contributi…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsAug 30, 2006
…filing fee. In the amended petition, petitioners
disputed deficiencies determined for taxable years 1997 and 2000,
and they attached a notice of proposed changes (Form CP-2000),
issued by respondent on June 9, 1999, proposing an increase to
petitioners’ 1997 taxable income. The income at issue for
taxable year 1997 was…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
T.D. 9166 — Final regulations under section 9801 of the Code provide guidance on the Health Insurance Portability and Accountability Act of 1996 (HIPAA) portability requir… IRCTreasury DecisionsFeb 22, 2005
…l regulations implementing the HIPAA provisions were first made available to the public on April 1, 1997 (published in the Federal Register on April 8, 1997, 62 FR 16894) (April 1997 interim rules) (T.D 8716, 1997-1 C.B. 225). On December 29, 1997, the Departments published in the Federal Register (62 FR 67688) a clari…
REG-130370-04 — Proposed regulations under section 9801of the Code would provide guidance on the HIPAA portability requirements relating to interaction with the Family and Med… IRCProposed Rules (FR)Proposed Feb 22, 2005
…l regulations implementing the HIPAA provisions were first made available to the public on April 1, 1997 (published in the Federal Register on April 8, 1997, 62 FR 16894) (April 1997 interim rules) (T.D. 8716, 1997-1 C.B. 225). On December 29, 1997, the Departments published a clarification of the April 1997 interim ru…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCRegulationsMay 18, 2016
…ses of satisfying the current availability requirement of § 1.401(a)(4)-4(b) for the portion of the 1997 plan year before the amendment, the group of employees to whom the right to direct investments is currently available, taking into account the amendment, must satisfy the nondiscriminatory classification test of § 1…
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsSep 25, 1996related by meaning
…er, docket No. 10897-93; and Frank A. Pettisani and
Lucille M. Pettisani, docket No. 23719-93.
T.C. Memo. 1996-435
UNITED STATES TAX COURT
BARRY B. BEALOR AND NANCY L. BEALOR, ET AL.,
1
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 13364-89, 14112-89, Filed September 25, 1996.
17236-89, 26434…
IRCCourt RulingsOct 11, 1995related by meaning
T.C. Memo. 1995-492
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed October 11, 1995.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Jud…
IRCCourt RulingsDec 18, 2012
…1992 through 1994 taxable years.
The case at docket No. 9276-03 involves Ms. Zaklama's 1995 through 1997
taxable years. The remaining case involves Mr. Zaklama's 1995 through 1997
taxable years. We use the term "subject years" to refer collectively to Ms.
Zaklama's 1992 through 1997 taxable years and to Mr. Zaklama's 1…
IRCCourt RulingsApr 23, 2001
…titioners are husband and wife. Petitioner Blaney H. Howle III (Mr. Howle) turned 62 on October 31, 1997, and
petitioner Polly T. Howle (Mrs. Howle) turned 62 on March 1,
1997. Mr. Howle has been retired on disability from railroad
employment since the age of 57.
In 1997, Mr. Howle received Tier 1 railroad retirement
b…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
T.C. Memo. 1999-80
UNITED STATES TAX COURT
EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC.,
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1616-97. Filed March 16, 1999.
Paul F. Markham
, for petitioners.
Mark L. Hulse
and Gary W. Bornholdt
, for respondent.
MEMORANDUM FINDINGS OF FACT A…
IRCCourt RulingsJan 23, 2001
spect of the
taxable year 1997.
Petitioners timely filed a joint Federal income tax return
(Form 1040) for 1997. On their return, petitioners reported total income of $79,300, consisting of wages of $79,271 and
taxable interest of $29. Petitioners deducted from total income
the $2,000 amount that had been contributed t…
IRCCourt RulingsDec 13, 2005
…the date the
contract is entered into or construction co mm ences ." S . Rept .
105-33 , at 30-31 ( 1997 ), 1997-4 C .B . (Vol . 2) 1067, 1110 ; H .
Conf . Rept . 105-220 , at 381 (1997), 1997-4 C .B . (Vol . 2) 1457,
1851 ; H . Rept . 105-148 , at 338 (1997), 1997-4 C .B . (Vol . 1) 319,
660 .
- 8 -
Further, to broadl…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…